Other states wrestle with it, too, said Jamie Abrams, an assistant professor of law at the University of Louisville, who thinks this case could be a prime example in an emerging school of thought — that actions by the court can play a part in an individual's lashing out in what is known as a "hypermasculine" act of violence.

"Courts are good at assessing risk of child abuse or domestic abuse, but these types of incidents are different: They are retaliatory of the loss of their parenting rights," she said. "The more rights that are taken away from (noncustodial parents), the more intense and angered they are. It's a very dangerous situation.